1986 (5) TMI 49

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....see for sales promotion could be considered as advertisement expenditure and disallowed under s. 37(3A). 2. The assessee is a firm having a business in textiles. They had incurred an expenditure of Rs. 55,796 for the asst. yr. 1979-80 in respect of advertisements etc. The ITO, invoking the provisions of s. 37(3A), disallowed 15 per cent thereof, i.e., Rs. 8,370. Before the CIT(A), the assessee h....

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....r the year 1979-80 is given below: Painting of the name board Rs. 7,554 Calendars Rs. 5,738 Rs. 13,292 Data Pads Rs. 821 Weekly Advertisements Rs. 500 Souvenirs Rs. 3,007 Rs. 17,620 We are unable to accept the assessee's submission that there is no element of advertisement in all of them. We will, however, accept that in painting the name-board there is no advertisement involved. The ....

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....ds purchased from the assessee have to be properly wrapped and if the name of the assessee is printed on these wraps it could not be considered purely as advertisement expenditure. Primarily they are for packing of the goods. So this amount has also to be excluded. The rest of the expenditure are properly treated advertisement expenditure. 6. For the asst. yr. 1980-81, there are 3 other points. ....